06-F Tax Proposal - LinebargerLINEBARGER GOGGAN BLAIR PENA & SAMPSON, LLP
Attomeys at Law
. 1517 W. FRONT ST., SUITE 202
P.O. BOX 2032
TYLER, TEXAS 75710
Telephone: (903) 597•2897
Facsimile: (903) 597-2402
November 2, 2001
Mr. Larry Schenk
Paris City Attomey
125 First Street SE
Paris, Texas 75460
Re: Request for Proposals for Delinquent Tax Collection Attorney for the City of Paris
Deaz Mr. Schenk:
Linebazger Goggan Blair Pena & Sampson, LLP is pleased to submit a proposal for collecting
delinquent taxes on behalf of the City of Paris. Our firm has maintained a highly effective and
thoroughly professional program for collecting delinquent taaces for entities in Lamar County.
I will serve as the chief contact between our firm and the City of Paris throughout these
discussions and am authorized to make representations on behalf of the firm. You may reach me
at the following address and phone number:
M. Elizabeth Vaughn, Attomey
Linebazger Goggan Blair Pena & Sampson, LLP
1517 West Front St., Suite 202
Tyler, Texas 75702
Phone: (903) 597-2897
Email: Liz.Vau hg_n(cr~publicans.com
Specific services offered in this proposal aze highlighted in the Executive Summary. Our firm ,
will work with the city throughout the contract/proposal period to address any questions or
additional services that may be required to maximize your collections. We firmly believe that
we can best serve the city, given our many years of experience in the region and the total
resources we commit to providing advanced collection technologies and professional personnel.
Over the past year our firm has been committed to the success of the Homestead Program
through our work with the Lamu County Appraisal District, our involvement in committee
meetings, and through our recent sign campaign to sell previously struck off property and we
will reaffirm this commitment if chosen to represent the City of the Paris in the collection of
delinquent taxes.
The City of Pazis' delinquent tax collection program would be managed from our Tyler office.
Our personnel devote their time exclusively to property tax collections. If the City of Paris has a
problem or question on tax collection practices and procedures, we will have qualified personnel
readily available to assist you. This assistance is available to all city officials, as well as the
city's administrative offices. Our personnel are always available to the City of Pazis via
telephone, facsimile, and the intemet. Additionally, we work in Paris on a regular basis each
month and are otherwise available with minimal notice.
We are committed to practicing property tax law full-time on your behalf. We believe you will
find no other firm in this business has invested the same level of resources towazds delivering
professional, personal service to its clients as we have. We are proud of our attomeys and staff
and appreciate the opportunity to submit this proposal for your consideration. If any additional
information would be helpful, please feel free to contact me.
Very truly yours,
~ 404 q
M. Elizabeth Vaughn
Attomey
LINEBARGER HEARD GOGGAN BLAIR GRAHAM PEIVA & SAMPSON, LLP
PROPOSaL FoR DEUnQUEnrr Tax * *
COLLEC110N SERVICES
City of Paris
Date
March 2001
Contact
M. Elizabeth Vaughn, Attorney
Phone: (903) 597-2897
Email: Liz.Vaughn@publicans.com
1517 West Front Street, suite 202, Tyler, Texas 75702 Tel: (903) 597-2897 Fax: (903) 597-2402
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Ciry ojParis Proposa( - Tab(e ojContents
TABLE OF CONTENTS
EXECUTIVE SUMMARY
-{~ILOSOPHY I
MEfHODOLOGY S. WORK PLAN I
:)CEDU . 4
IJ'+TARY SEIZURE m KRUPTCY PROC......................................... 6
MANAGEMENT TEAM
EXH I B fT5
PROPOSED MANAGE
THE CITY OF PARIS
THE CITY OF PARIS
CENTRAL SUPPORT
A. CLIENT LIST
B. SAMPLE CONTRACT
I
I
2
3
3
Lrne6arger Heard Goggan Blair Graham Pefia & Sampson, LLP
Fxecutive Summary -7
Ciry ojParis Proposa[ - Erecutrve Summary
Bankruptcy Representation: Our Bankniptcy Department offers full representation and
aggressive pursuit of all bankruptcies affecting the City of Pazis's delinquent taac claims to assure
prompt and maximum recovery.
Title Work and Lienholder Notices: We will obtain a complete title report on every real
property lawsuit. We will notify all lienholders and interested parties of any lawsuits filed to
collect delinquent taxes.
Taxpayer Locator Service: Using local, state, and nationwide database search tools, we will
reseazch bad addresses until the City of Pazis's delinquent taxpayers are located, notified of their
delinquent status, and put into an active collection program.
Local Representation: We are immediately available by telephone or in person for meetings,
conferences, consultations, hearings, or other related tax matters on a daily basis. Our collection
program will be customized to fit the specific needs of the city.
Personal Service for City of Paris Taxpayers: Our Tyler office is staffed by attorneys,
collectors, and litigation assistants who aze available to meet with taxpayers in person and to
respond to all phone inquiries and letters from taxpayers. We regulazly meet with taxpayers to
help them arrange payment of their delinquent taxes.
Regular Performance Reports: We will submit regulaz performance reports describing
collection efforts and the results achieved on behalf of the City of Pazis. All other periodic
reports will be provided in writing if requested or presented orally at the client's discretion.
Computer Support: Our data processing system retains a complete history of all collection
activities related to individual accounts, including payments, corrections, reports, litigation
tracking, address reseazch, etc.
•
Linebarger Heard Goggan B[air Graham Pena & Sampson, LLP -*4#
Executive Summary -8
City ojParrs Proposa! - Executive Summary
ADDITIONAL SERVICES PROVIDED
Collections Analysis: We will prepaze an in-depth analysis of the delinquent tax roll in order to
develop the most effective collection work plan for the city.
Complex Civil and Civil Appellate Litigation: We will represent the City of Paris at no cost, in
all types of lawsuits arising from collection activities, such as counterclaims, injunction suits,
eminent domain proceedings, declazatory judgment actions, and all types of complex property
tax related litigation. We aze well qualified to assist the City of Pazis in this azea as several of
our attomeys aze Board Certified in Civil Trial Law by the Texas Board of Legal Specialization.
Legislative Services: We maintain an Austin office which offers legislative services that include
bill status research, document acquisition, and regulaz legislative reports to city officials on any
legislative matters affecting the Property Tax Code or the welfaze of the city.
Media Relations: With the city's approval, experienced public relations professionals will
integrate media coverage into the City of Paris collection program to inform property owners of
their responsibilities and deter delinquency.
Taxpayer Assistance/Educatioa: Our local staff can make presentations to community groups
or organizations interested in learning more about property taxation and taxpayers' rights as
requested by the City of Paris.
Toll-Free Networking: Our toll-free telephone nerivork offers access to all of our offices and
legal counsel experienced in bankniptcy, appraisal district matters, and complex civil litigation
statewide at no cost to the City of Paris.
Linebarger Heard Goggan BJair Graham PeRa & Sampsors. LLP
1~1
Executive Summary -I
Executive Summary
FIRM BACKGROUND
Linebazger Heard Goggan Blair Graham Pena & Sampson, LLP understands government
receivables like no other law firm in the United States. Linebarger Heard has 21 full-service
offices in Texas and over 600 support personnel, including more than 70 attomeys who
practice ad valorem tax law exclusively.
We pride ourselves on a thorough, professional understanding of property tax law at every
level. Our attorneys and staff are committed to meticulous attention to detail throughout the
collection process, whether examining records in the tax office, prosecuting lawsuits in the
courtroom, or appearing before goveming bodies to report the results of our efforts.
Our law firm provides
full-service property
tax representation to
more than 1,600
taxing entities
statewide, including
112 Texas counties,
492 Texas school
districts and the cities
of Houston, Dallas, EI
Paso, and San
Antonio.
In our 25 yeazs of
collecting delinquent
Rict
taxes, we have
developed proprietary
collection softwaze
programs that
integrate mass and
specialized mailings,
telecommunications,
address and
ownership research, tradi6onal trial advocacy, and post judgment enforcement using advanced
computer technologies. Our firm has invested more than $25 million in data processing and
digital communica6ons technologies for the sole purpose of collecting government
receivables.
r
Linebarger Heard Goggan Blair Graham Pena & Sampson, LLP
Executive Summnry -2
Ciry af Paris Proposal - Executive Summary
Linebarger Heard has served clients in Lamar County for over 13 yeazs. The history of the
firm's northeast Texas offices began in 1983 when we established an office in Tyler. At the
time, the Tyler office had a staff of just three people and two clients. By 1988 our client base
had grown to 65 taxing entities, all of which aze still with us today.
Our firm offers the City of Paris the expertise and resources of a statewide law firm, and a
well-established, responsive, and successful delinquent tax collection program in Lamar
County. Our Tyler office is fully staffed by collection professionals (attorneys, collectors, and
lidgation specialists) who are readily available, five days a week, to taxpayers who wish to
make payments or discuss their accounts in person. Clients served by Linebarger Heazd's
Tyler office can count on the legal experience of Attorneys M. Elizabeth Vaughn and Jim
Lambeth, and Partner ponald Lee Wolf when turning over their delinquent tax accounts for
collection. Our attorneys rely on experienced legal assistants with personal knowledge of the
communities they serve. All administrative work is handled by highly qualified legal
secretaries.
Our Tyler office personnel have earned our North and East Texas clients' respect and loyalty
as a result of our successful collection methods and the personal and professional attention
they give to local taxpayers.
Our local office offers the City of Paris a bankruptcy program that aggressively pursues
accounts in bankruptcy, as well as address research, taxpayer assistance, and telecollections
programs to maximize collections in a systematic manner.
All of our 21 statewide offices aze connected by means of a dedicated wide area network to our
proprietary database system, which supports all aspects of our delinquent tax collection
program, from mailings and address research to bankniptcy litigation and tax sales.
Our softwaze programmers have developed several proprietary softwaze programs for
managing delinquent tax colleclions and payment agreements. Other in-house soFtwaze
maintains timely information on all litigation and bankruptcy activities that our personnel will
initiate on behalf of the City of Paris to assure that no collection opportunity is overlooked. '
Line6arger Heard Goggan Blair Graham Pena & Sampson, LLP
Execuave Summary -3
Ciry of Paris Proposal - Executive Summary
(
LINEBARGER HEARD GOGGAN BLAIR GRAHAM PEIVA & SAMPSON, LLP
Our Tyler and Longview offices proudly represent tasing units within the counties shown on the
map below. A list of these taxing units is shown on the next page. We have also attached a firm-
wide delinquent tax client list as ExhibitA.
TYLER & LONGVIEW OFFICES
AREA OF REPRESENTATION
Linebarger Heard Goggan Blair Graham Pena & Sampson, LLP
Executive Summary -4
Ciry of Pa- Executive Sununary
LINEBARGER HEAR`D REPRESENTS THE FOLLOWING ENTITfES IN NORTHEAST TEXAS
CAMPCOUNTY
CampCounry
Camp CAD
Northeast TX CC Dist (Camp)
Pittsburg
Pittsburg ISD
Rocky Mound
CASSCOUNTY
Atlanta
Atlanta ISD
Avinger
Avinger ISD
Bloomburg
Bloomburg ISD
Cass CAD
Domino
Hughes Springs
Hughes Springs ISD
linden - Kildare CISD
Marietta CISD
Mcleod ISD
Pewitt ISD
Queen CRy
Queen City ISD
CHEROKEECOUNTY
Atto
AAO ISD
Cherokee CAD
Jacksonville ISD
New Summerfield ISD
Rusk
Rusk ISD
Troup ISD
Wells
Wells ISD
DELTA COUNTY
Cooper
CooperlSD
Defla CAD
DeHa County
Defla County MUD
Fannindel ISD
Pecan Gap
FANNIN COUNTY
Bailey
Bonham
Bonham Water Authority
Dodd City
Dodd Ciry ISD
Eclor
Ector ISD
Fannin CAD - Collector Ony
Fannin Co Wtr Authoriry
Fannin County
Fannindel ISD
Honey Grove
Honey Grove CISD
Ladonia
Leonard
Leonard ISD
Sam Raybum ISD
Savoy
SavoylSD
Trenton
Trenton ISD
Windom
Windom ISD
FRANKLIN COUNTY
Mount Vemon ISD
SaMillo ISD
Sulphur Bluff ISD
GREGG COUNTY
Clarksville City (Gregg)
Easton
Gregg Co Rural FPD #1
Gregg County
Kilgore
Kilgore College
Kilgore ISD
Lakeport
Liberty-Danville FWSD # 02
Longview
Sabine ISD
Spring Hill ISD
White Oak
HENDERSON COUNTY
Brownsboro ISD
Eustace ISD
Kemp ISD
Mabank ISD
Malakoff
Malakoft ISD
Star Harbor
Trinity Valley Comm Coll Dist
HOPKINS COUNTY
Como
Cumby
Cumby ISD
Hopkins CAD
Hopkins Co HD
Hopkins County
Miller Grove ISD
North Hopkins ISD
Saltillo ISD
Sulphur Bluff ISD
Sulphur Springs
Sulphur Springs ISD
HUNTCOUNTY
Bland ISD
Caddo Mills
Caddo Mills ISD
Commerce
Commerce WD
CumbylSD
Greenville
Greenville ISD
Hunt County
Huni HD
Lone OakISD
Quinlan
Quinlan ISD
Wol(e City ISD
KAUFMAN COUNTY
Crandall
Crandall ISD
Forney
Fomey ISD
Kaufman
Kaufman CAD
Kaufman Counry
Kaufman ISD
Kaufman Rural FD # 01
Kemp
Kemp ISD
Kemp Rural FD # 04
Mabank
MabanklSD
Mabank Rurel FD # 02
Oak Ridge
Scurry - Rosser FD q 05
Scurry • Rosser ISD
Terrell
Terrell ISD
Terrell Rural Fire Dist # 03
Triniry Valley Comm Coll Dist
LAMAR COUNTY
Auds Creek WD
Blossom
Chisum ISD
DepoA
Lamai CAD
LamarCounty
Logans-Sbugh WD
North Lamar ISD
Paris ISD
Paris Jr Coll Dist
Pine Creek WD
Prairiland ISD
Reno
Roxton ISD
MARION COUNTY
Jeflerson
Marion CAD
Marion Co HD
Marion County
MORRIS COUNTY
Daingerfield
Daingerfield • Lone Star ISD
Lone Star
Morris CAD
Morris Co HD
Morris County
Naples
Northeast Tx Comm Coll Dist
(Morris)
Omaha
PANOLA COUNTY
Beckville City
Elysian Fields ISD
RAINS COUNTY
East Tawakoni
Emory
Miller Grove ISD
Point
Rains County
Rains County FD
Rains County TAD
Rains ISD
Upper Sabine Waste Disp Dist
RED RIVER COUNTY
Mnona
Avery
Avery ISD
Bogata
Clarksville (Red River)
Clarksville ISD
Detroit
Detroit ISD
Lang(oM Creek MUD
Red River CAD
Red River Co WD
Red River County
Rivercrest ISD (Talco-Bogata
CISD)
Linebarger Heard Goggan Blair Graham Pefia & Sampson, LLP
F.xecutive Summary -5
Proposal -aecutive Summary
RUSKCOUNTY
BullardlSD
TitusCAD - CollectorOnly
CarlislelSD
ChapelHiIIISO
TilusCounty - CollectorOnly
Gregg Co Rural FPD # 01
Emerald Bay MUD
Henderson
Lindale
UPSHUR COUNTY
Henderson ISD
Lindale ISD
Big Sandy (Upshur)
IGlgore College
Smith CAD
Big Sandy ISD (Upshur)
laneville ISD
Smith Co Rural FPD # 01
East Mountain
Leveretts Chapel ISD
Smith Co WD # 01
Gilmer
Mt Enterprise
Smith County
Gilmer ISD
Mt Enterprise ISD
Troup
Harmony ISD
New London
Troup ISD
New Diana ISD
Ovedon
Tyler
Ore Ciry
Ovedon ISD
Tyler ISD
Ore City ISD
Rusk Co FPD # 01
Tyler Jr Coll
Union Grove ISD
Rusk County
Whitehouse
Union Hill ISD
Rusk ISD
Whitehouse ISD
Upshur CAD
Tatum ISD
Winona
Upshur Co FD # 01
West Rusk Co CISD
Winona ISD
Upshur County
SMRHCOUNTY
TRUSCOUNTY
VAN ZANDT COUNTY
Arp
DaingerField - Lone Star ISD
Trinity Valley Comm Coll Dist
Arp ISD
Northeast Tx Comm Coll Dist (Titus)
Tyler Jr Coll
Bullard
Talco
Van Zandt CAD
WOODCOUNTY
Alba
Alba - Golden ISD
Hawkins
Hawkins ISD
Upper Sabine Waste Disp Dist
Winnsboro
Winnsboro ISD
Wood CAD
Wood Co Central Hosp Disl
Wood County
Yantis
Yantis ISD
Linebarger Heard Goggan Blair Graham PeAa & Sampson, LLP
Executive Summary -6
City ojParis Proposa! - Executive Summary
DELINQUENT TAX OPERATIONS
Comprehensive Collection Program: We will provide comprehensive delinquent tax collection
services and legal representation for any tax lawsuit, property assessment, real estate matter, or
dispute as it pertains to the collection of property taxes.
Aggressive Collection Strategy: All eligible accounts will be placed in an active collection
program, ranging from collection calls and multiple notification letters, to filing tax suits and
conducting tax seizures, foreclosures, and sales.
Taxpayer Notification and Personal Coutact: We believe that many taxpayers need to receive
more than a collection letter to prompt them to payment. For this reason, we supplement our
mass and tazgeted mailings carried out during the yeaz with collection calls to taacpayers to
resolve their delinquent accounts.
Phone Collections: We operate a full-time call center to enhance collections through a high
volume of personal contacts with all eligible delinquent taYpayers and lienholders.
Automated Dialer: We have created a statewide collection unit that utilizes an automated dialer
that can place thousands of calls a day to delinquent taxpayers. This technology, known as a
"predictive dialer," has been used by commercial collection agencies for years. The system
automatically dials pre-loaded accounts and instantaneously assigns calls to a collector when
someone answers the call.
Property Seizures (Business Personal Property): Due to the perishable nature of business
personal property, the city's tax assessor-collector and our firm will employ tax warrants on a
regulaz basis as a means of increasing collections.
Litigation Services: Linebarger Heazd will provide an effective litigation program for the city
which is responsive to the desires of the city and tax office. The City of Pazis can rely upon
Linebazger Heazd to file quality lawsuits that are well reseazched and moved through the .
litigation process in a timely manner.
Foreclosures and Tax Sales: At times it becomes necessary to reduce a judgment to sale. This
is an integral part of our collection program which we cany out in a manner that gives property
owners every chance to make payment of taxes to prevent the sale of their property.
Resale Program: We will assist the City of Pazis in pursuing a comprehensive foreclosure
program, including the resale of properties that do not sell at sheriff tax sales.
Linebarger Neard Goggan Blair Graham PeAa & Sampson, LLP
Fxecutive Summary -9
City ojParis Proposal -Executive Summary
We have provided below references of other taxing agencies for which Linebazger Heazd Goggan
Blair Graham Pena & Sampson, LLP provides delinquent tax collection services. A listing of
over 1,600 clients that have retained our law firm is included as Exhibit A. No other law firm in
Texas can provide as broad a range of clients and collection experience - from urban to nua1,
lazge to small - as Linebazger Heazd.
We invite you to contact any of our clients to discuss our law fum, our wllection efforts and services,
and the results that we achieve for our clients.
Ms. Elaine P. Ballard
Superintendent
Paris ISD
P. O. Box 1159
Pazis, Texas 75461
903/737-7473
Mr. Harvey B. Hohenberger, Jr.
Superintendent
Chisum ISD
3250 Church St.
Paris, Texas 75462-9804
903/737-2830
Mr. James A. Dawson
Superintendent
North Lamar ISD
3201 Lewis Lane
Paris, Texas 75462-2092
903/737-2000
Honorable M. C. Superville, Jr.
County Judge
Lamar County
119 N. Main St.
Paris, Texas
75460
903/737-2410
Mr. James O. Hesson
Superintendent
Roxton ISD
P. O. Box 307
Roxton, Texas 75477-0307
903/346-3213
Mr. James Morton
Superintendent
Prairiland ISD
Rt. 1, Box 200
Pattonville, Texas 75468-9801
903/652-6476
Ms. Cathy Jackson
Chief Appraiser
Lamar CAD
P. O. Box 400
Pazis, Texas 75461
903/785-7822
Ms. Pat Loven
Collections Supervisor
Lamar CAD
P. O. Box 400
Paris, Texas 75461
903/785-7822
Linebarger Heard Goggan Blair Graham PeNa & Sampson, LLP
Fxecutive Summary -10
Paris Proposa! - Executive Summaty
We will provide all of the services outlined in this proposal for fifteen percent (15%) of the
total tax, penalty, and interest collected by the law firm and deposited into the City of Pazis
Treasury.
No fee is payable until the tax money collected by the law firm is in the City of Paris
Treasury. Our fee includes all mailing, title, reseazch, and publication costs associated with
our collection program. It also includes unlimited legal advice in response to telephone or
letter inquiries, attendance at official meetings, and appeazances at other non-litigation
functions where our presence is requested or required.
Our firm also provides comprehensive bankruptcy litigation services including nationwide
representation for 15% of all taxes, penalties, and interest collected by our attorneys. There
is no additional chazge to the City of Pazis for this service.
The city is not liable for any cost not included in this proposal. All fees will be payable on a
monthly basis. A sample contract is provided as Exhibit B.
Line6arger Heard Goggan Blair Graham Pena & Sampson, LLP
Ch. !-1
Ciry ojParis Proposal - Collection Program I
1. Collection Program
COLLECTION PHILOSOPHY
The successful collection of delinquent taxes is uniquely dependent upon the personal
efforts, technical support, and solid planning of the law firm entrusted with this
responsibility. Our firm has assembled qualified, experienced people with specific fields of
expertise who can assist its clients with difficult ad valorem tax issues and assist its
employees in the field. This philosophy assures professional services and personal attention
to every taxing entity we represent.
Computer systems complement the efforts of our experienced property tax staff and are
invaluable to our operations. We maintain a full-service information resources division,
capable of handling any taxing entity's delinquent tax collection needs.
COLLECTION METHODOLOGY & WORK PLAN
Our collection program merges the discipline of law with the business of debt collections
using highly sophisticated computer systems. While our collection program relies heavily
upon data processing techniques to manage vast numbers of accounts, we aze successful
lazgely due to the personal attention we expend in our litigation and collection efforts for
our clients.
All taxpayers aze treated with politeness and professional courtesy. Our firm has developed
a reputation for implementing aggressive, but fair collection strategies that achieve
maximum results. Although our collection strategy is based upon the maximum
automation that technology will permit, the most advanced technology cannot furnish the
discretion, judgment, or compassion necessary to deal appropriately with taxpayers'
responses to a mailing. By notifying all taxpayers, regazdless of amounts due, and
providing a well-trained staff, we endeavor to facilitate the payment of taxes.
Work Plan
Our law firm develops and utilizes work plans as a management tool for both immediate
and long-range planning. The work plan developed for each client is based on our monthly
analysis of the client's delinquent tax roll (DTR) and is customized to accommodate the
collection style and approach advocated by the jurisdiction. A detailed profile of the
delinquent tax roll is produced monthly to assist with the tracking of collections and the
identification of tazget azeas requiring special attention.
Linebarger Heard Goggan Blair Graham Pena & Sampson, LLP
City of Paris Proposa( - Co!(ection Program Ch. 1-2
We emphasize not only working hazd, but working smart. We use our technology to
analyze the tax roll and identify azeas where we can masimize the revenue collected for
each client. By analyzing the DTR and then customizing a collection program for the City
of Paris we can assure the most efficient allocation of resources for consistent, long-term
increases in coliections.
Linebarger Heard Coggan Blair Graham Pett"a & Sampson, LLP
The following is a monthly work plan outlining the activities we will implement for
collecting delinquent City of Pazis taxes with the city's approval.
Ch. I-3
City of Paris Proposa[ - Collection Program
t
Legal Remedies
Our firm has the capacity to generate and manage as many lawsuits as the local court
system can effectively handle. We prepaze the petitions, citations, and address labels (when
using service by certified mail) in accordance with the Texas Rules of Court, Texas
Propertv Taac Code and local court rules.
We will file on all the accounts targeted for lawsuit unless otherwise directed by the tax
office. And, we will prosecute every lawsuit we file as quickly as logistics pernut. Once
service is obtained on all defendants in a particulaz case, we will immediately set the
lawsuit for trial.
An overview of our tax suit, summary seizure, and bankruptcy procedures are provided in
this section. While we vigorously pursue all lawsuits we file, we will also make every
possible opportunity available to your delinquent taacpayers to pay their taxes and avoid any
additional fees.
To be successful, a collection effort must be consistent. An aggressive, highly visible legal
campaign lends vital credibility to the collection process and makes the demand letter and
telephone contact program more effective. We choose accounts carefully for lawsuit,
emphasizing high dollaz/high profile accounts. All accounts that are not capable of being
resolved by demand letters or phone contact and aze not in bankruptcy or otherwise
protected are placed in suit.
Our task is to educate delinquent taxpayers on the consequences of disregarding their tax
obligations, such as the sale of their property and imposition of heavy penalties, interest,
court costs, and attorneys' fees. An efficient delinquent tax collection program makes good
taxpayers out of non-paying taacpayers.
.
Linebarger Heard Coggan Blair Graham Pena & Sampson, LLP
Ch. !-4
City of Paris Propasal - Callectron
TAX SUIT PROCEDURES
. . . e
. - . . . Sue
~ . paYments, ~ prepares pleadings
and . ,
g .
their , . .
Default ' g • Ib Fails to
after . p• • . p . • ♦ apPear ~ . . , APPears ~ ' '
d: • d
m, . owing entry of judgnient
m
Linebarger Henrd Goggan Blair Graham Pena & Sampson, LLP
Ch. I-5
Ciry of Paris Proposal - Co![ection Program
TaxI warrants az•e an extremely effective tool in collec6ng delinquent business personal
property accounts. Approximately 80 percent of our seizures result in immediate payment
of delinquent taxes without the necessity of actually executing the warrant. The remaining
seizures generally recover the taxes due from the proceeds of the sale of the personal
property.
The firm has conducted hundreds of tax seizures for its clients. The use of a tax warrant
requires an inidal on-site inspection and consultation with the client. If a determination is
made to issue a tax warrant, our firm will make all necessary prepazations to secure the
property, which will be seized and ultimately sold.
SUMMARY SEIZURE PROCEDURES
Linebarger Heard Goggan B(air Graham Pena & Sampson, LLP i•~~
Ch. I-6
Ciry of Paris Propasal - Collecfion Program
Our firm has extensive ex erience in re resentin I
P p g governmental entities in Bankruptcy
Court. We have four comprehensive bankruptcy departments fully prepared to actively
pursue collections of ad valorem taxes in bankruptcy proceedings throughout the state.
We also actively pursue bankruptcies throughout the United States, with our attorneys
routinely representing clients at hearings held outside the State of Texas. To protect the
rights of our clients as creditors, we assign staff to be responsible for the filing of proofs of
claim, monitoring the progress of the cases, communicating with debtors' attorneys,
submitting ballots, filing timely motions, attending creditors' meetings, and arguing cases
before the bankruptcy judges. Our pro-active stance in bankruptcy cases assures that our
clients' rights aze protected.
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM pENA & SAMPSON, LLP
BANKRUPTCY PROCEDURES
~
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f flNAtptPoRl
CONFIRIdAhI0UNi5GAlD
PAYMEN1i0
COUIf191tH
DIAFCt10NS01!
Ml\' 10 AC4LY
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Linebarger Heard Goggan Blair Graham Pena & Sampson, LLP
Ch. 1/-7
City ofParisProposal-ManagementTeam
11. Management Team
Our firm has an office in Tyler to serve City of Paris clients and taxpayers. Our Tyler office
personnel will support the day-to-day collection strategies authorized by your collection
management team to meet the specific work plan for maximizing City of Pazis collections.
They will also provide personalized attention to the needs of the city's taxpayers who want to
resolve their delinquent taxes.
Our Tyler office is staffed by over 20 professionals, including attorneys, pazalegals, litigation
assistants, collectors, reseazchers, data specialists, and administrative personnel. In addition,
this office is part of Linebazger Heard's strong statewide network of offices.
Linebazger Heazd's collection program is the combined effort of our attorneys and collection
employees, baukniptcy and management teams, computer professionals, and administrators
from our 20 offices throughout the State.
PROPOSED MANAGEMENT TEAM
In summary, the City of Paris has the potential to contract with the strongest collection team
available to work on its delinquent tax accounts. Our combined workforce of 600 plus
employees, including more than 70 attorneys, represents a formidable collection force, one
with considerable experience and broad expertise in the azea of tax collections. Their
biographies aze provided at the end of this chapter.
THE CITY OF PARIS COLLECTION SUPPORT TEAM
Collectors: This team oversees all aspects of collections, from ordering and monitoring all
delinquent tax mailings to arranging and collecting payments from taxpayers. They work
very closely with the taxpayer assistance personnel and the tax collector's office.
Linebarger Heard Goggan Blair Graham Pen"a & Sarrtpson, LLP
Ch. II-2
City ojParrs Proposal - Management Team
f
They are directly responsible for implementing the work plans for the City of Paris, in
concert with the City of Paris management team.
Litigation Support: This group monitors all tide reseazch efforts and is responsible for
preparing account files for litigation. T'hey review tax office records, check the market value
of the account, and look for any special assessments or liens on the property. They prepaze
pleadings and citations and file them with the district clerk's office.
ResearCh: The Research Department scrutinizes all title work and conducts reseazch on all
bad addresses. Members of this department aze experienced in using a variety of tools from
dynamic, on-line state and national commercial databases to the more traditional reseazch
methods, like drivers' licenses and voter registration records. Staff works closely with the
litigation support team to locate all owners or parties of interest on a delinquent account prior
to filing a lawsuit.
Taxpayer AssistanCe: This group has yeazs of experience in tax collections. They handle
all inquiries professionally and work to make every incoming call a collection. In addition
to responding to all taxpayer inquiries, this team monitors payment agreements. They work
closely with our bankruptcy division, sending personalized notices to each account as it is
dismissed or dischazged from bankruptcy.
Office Support: Our support staff handles all data entry for tracking collections and
litigation and any additional document prepazation required by collection personnel or
attorneys.
THE CITY OF PARIS SPECIALIZED COLLECTION TEAMS
Bankruptcy: The Bankniptcy Department offers complete legal services and representation
to the City of Pazis in all bankruptcy courts within the continental United States. This group
processes all proofs of claim, prepazes and files all necessary documents, and represents
clients at creditor meetings and/or in bankruptcy court.
Phone Bank Collections: The phone bank operators make personal contact with
delinquent taxpayers to make arrangements for paying delinquent taxes according to the
clienYs specific terms for payment agreements. This group is trained to handle difficult or
irate taxpayers in a manner that generally results in positive collections for the City of Paris.
Foreclosure Property Marketing: This group handles all properties set for tax sales and
provides additional marketing strategies for properties that do not sell at an initial tax sale.
They process all foreclosed properties, publish public norices, and conduct tax resales to
retixrn property owned by the City of Paris to the active tax roll. They also work closely with
realtors and other investment groups to sell properties that aze "struck ofP' the tax roll.
Linebarger Heard Goggan Blair Graham Pefia & Sampson, GLP
Ch I!-3
City ojParrs Propasal-Management Team
CENTRAL SUPPORT GROUP
Information Technology: This group of programmers, analysts, and technicians provides
statewide data processing support for all collection and litigation activities. Data processing
personnel process client tax roll data and provide detailed tax roll analyses for the delinquent
tax collection program. This department also oversees all mailings and the production of
computer-generated lawsuits. Our litigation and baukruptcy activities aze monitored through
proprietary case tracking software developed and maintained by this group.
Taz Mailings: As part of the IT Group, the Mail Room personnel handle all operations
necessary to send out statements pre-sorted and tagged, as required by the U. S. Postal
Service. Depending on the type of mailing requested, the process may include the addition of
special or bilingual notices. This group also tracks all returned mail, which is entered into a
special mail room database, and then given to our research departrnent staff to locate an
accurate address.
BIOGRAPHIES
Scott D. Wylie, Partner, based in Corsicana, Texas was admitted to the Texas Bar in 1981
after receiving a BBA degree from Baylor University and his Juris Doctorate degree from St.
Mary's University in San Antonio. Before entering law school, Scott was employed as an
intern with a federal bank examining agency and later served as an assistant to trust officers
with InterFirst Bank Corporation. While in law school, he received certification to practice
law under supervision, which allowed him to try cases for the Bexaz County Attomey's
office until his graduation in December 1980. Upon receiving his license to practice law, Mr.
Wylie became an Assistant District Attorney for Dallas County, where he was a felony
prosecutor in the Specialized Crime Division prosecuting more than 200 criminal cases to
conclusion.
In 1983, Mr. Wylie entered private practice in Dallas, where his practice was devoted almost
exclusively to civil litigation, including personal injury, medical malpractice, products
liability, land condemnation and workmen's compensation cases. In 1987, he brought his
litigation experience to the Linebazger Heazd Law Firm, where he is responsible for all Types
of litigation experienced by our clients. He has disposed of civil litigation for both our tax
collection and appraisal district clients in more than 100 counties.
Mr. Wylie became a partner in 1993 and has been the regional managing partner of the North
and East Texas offices since 1994. Mr. Wylie has been a member of the Dallas County,
Navarro County, and Travis County Baz Associations. He served two yeazs as a director for
the Texas Young Lawyers' Association and has been active in both the Texas and American
Trial Lawyers' Association. In addition to being licensed by the State Baz of Texas, he is
also licensed to practice in the U.S. District Court for the Northern and Western Districts of
Texas.
Linebarger Heard Goggan Blair Graham Pena & Sampson, LLP
Ch /I-4
City ofParis Proposal -Management Team
Mr. Wylie has over eleven years of experience in delinquent tax collection, appraisal district
administration and litigation associated with both delinquent tax collection and appraisal
district appeals. As a result, he frequently serves as a speaker for numerous tax and appraisal
related organizations and associations.
M. Elizabeth "Liz" Yaughn, Attorney, works out of the firm's Tyler office handling a11
aspects of delinquent property tax matters.
Ms. Vaughn received her Bachelor of Arts degree in Business Administration from Austin
College in Sherman, Texas in 1994. After doing post-baccalaureate work at Baylor
University in Waco, Texas, she completed an M.B.A. from St. Mary's University in San
Antonio. She received a J.D. from St. Mary's University School of Law in 1999, making the
Dean's List in the spring of 1999.
While in law school, Ms. Vaughn clerked for Hervol, Hinders & Goodbread in San Antonio
primazily working on bankruptcy, property law, family law, civil litigation, and federal
criminal defense. She also served as a reseazch assistant to Professor Mazsha Huie in matters
of Texas Civil Procedure and European Union law. She then interned with the Department of
Justice United States Trustee's Office in San Antonio, researching and authoring memoranda
on issues arising in pending bankruptcy cases.
Ms. Vaughn is a member of the Order of Batristers. She was active in the advocacy
competitions at St. Mary's University School of Law, and was selected for the St. Mary's
Law School Texas Young Lawyers Association State Moot Court Team.
In her spaze time Ms. Vaughn enjoys international travel, recreational sports, and reading
novels.
Monica McCoy Purdy, Parfner, is from Tampa, Florida and attended public schools in that
city. She graduated cum laude from Spelman College in Atlanta, Georgia, with a Bachelor of
Arts degree and major in Political Science.
Ms. McCoy-Purdy attended law school at Thurgood Mazshall School of Law at Texas
Southern University in Houston, Texas and received her poctor of Jurisprudence in May
1992. She was a publishing member of the Thureood Mazshall Law Review and served as
Publicist of the James M. Douglas Board of Advocates.
Upon graduation she interned with the delinquent tax litigation division of the Harris County
Attorney's Office and extensively reseazched appraisal, assessment and administrative issues
involving Harris County taxpayers. She joined Linebazger Heazd Goggan Blair Graham
Pena & Sampson, LLP in February 1994 in the firm's Houston office representing Cypress-
Fairbanks Independent School District, North Forest Independent School District and the
City of Prairie View. In addition to being licensed by the State Baz of Texas, she is also
Linebarger Neard Goggan Blair Graham PeAa & Sampson, LLP `.V.
Ch. IFS
City oJParis Propasal - Managemenl Team
licensed to practice before the United States District Courts for the Northern and Southem
District of Texas.
Ms. McCoy-Purdy transferred to the firm's Fort Worth office to handle delinquent taac
collection matters for various taxing entities during the first quarter of 1996. She has more
than six yeazs experience in delinquent tax collection matters.
Linebarger Heard Goggan Blair Craham Pena & Sampson, LLP
Ch III-1
Computer Resources & Services
f
I11. Computer Resources & Services
We have pioneered technological innovations in delinquent tax collection processes for more
than 25 yeazs. As a major high technology employer, we provide data processing and other
computer resources to governmental entities throughout Texas. Our representation of the
lazgest taxing jurisdictions in Texas has led us to invest millions of dollazs in the most
advanced data processing and communication technologies in the business. This investment
has enabled us to develop softwaze applications that meet the changing needs of the tax
collection process.
Proprietary Software
Recognizing our clients' growing needs for sophisticated softwaze applications, we directed
our systems designers and computer programmers to develop specialized applications, using
the latest technology to meet specific client needs. The result has been the development of
several proprietary softwaze systems specially designed to support all aspects of delinquent tax
collection, including mailings, reseazch, litigation, bankruptcy, and taxpayer assistance.
Our computers can process payments, corrections, and updates to the delinquent tax database
as often as our clients desire, whether it is daily, weekly, or monthly. This computer system
also provides code activity updates for the tax office database on a weekly basis, or at other
intervals as specified by city personnel. Our softwaze is designed to combine multiple
accounts into a single statement for your taxpayers.
Delinquent Tax Collection Support Systems
The design of our delinquent taat collection support softwaze is predicated on the belief that
the ultimate repository of all tax information is and should be the tax records of the taxing
jurisdiction. Therefore, no attempt is made within this system to pazallel the dynamic file
maintained by the jurisdiction unless we aze asked to do so. Rather, the delinquent tax
collection support system is updated when periodic copies of the jurisdiction's current files are
received. With our clients' permission, we will install modems in their tax offices to assure
that their taxpayer assistance clerks and legal assistants have immediate access to the latest
records of payments and adjustments.
Our data processing system retains a complete history of all collection activities related to
each delinquent account. This history includes the tracking of address changes, increases or
Linebarger Heard Goggan Blair Grakam PeAa & Sampson, LLP
Ch. ll/-2
City ojParis Proposa! - Computer Resources & Services
decreases in tax owed, taxpayer inquiries received by our office, the date and type of each
mailing, as well as codes to indicate whether a letter was returned undelivered. Any type of
special history information that may be required can be easily produced from our system.
The proprietary softwaze we have developed has been refined through years of actual use to
support all aspects of our delinquent tax collection program, including litigation and
bankruptcy proceedings. This software's open azchitecture takes full advantage of the
complementary features of other computer systems, from lazge mainframes to desktop micro-
computers, allowing maximum efficiency with personalized taxpayer service.
DATA TRANSFER
We have invested considerable personnel and capital resources in our automated systems. As
such, the media (tape, diskette, etc.) by which data is transmitted is not an issue for our clients.
Our Information Resources Division is familiaz with all the major software vendors in Texas
and has installed the appropriate equipment and trained our staff to handle their products.
LITIGATION TRACKING SYSTEM
We use a sophisticated on-line tracking system designed for the specific use of our attorneys,
paralegals, and litigation assistants, to manage lawsuits filed on behalf of our clients. This
system allows litigation staff to query and update all information regazding defendants,
plaintiffs, tax amounts, legal descriptions, account numbers, and the general litigation status of
each lawsuit.
BANKRUPTCY TRACKING SYSTEM
Our bankruptcy software tool is an on-line tracking and document generation system that
coordinates all bankruptcy-related collection activities. The system's centralized file design
allows for the consolidation of multiple client and account cases into one bankruptcy case
entry. This permits easy tracking, quick analysis, and fast document prepazation for pending
baukruptcies and client accounts on a statewide and national basis. It also identifies accounts
ready for collection or suit.
Linebarger Heard Goggan Blair Graham PeAa & Sampson, LLP
A
DELINQUENT TAX CLIENT LIST
CITIES REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIIi
GRAHAM PENA & SAMPSON LLP
- AGUA DULCE
• ALAMO
- Bl00MING GROVE
- CORPUS CHRIS77
- ALBA
- BLOSSOM
- CORRIGAN
- ALEDO
- BOGATA
- CORSICANA
- ALTO
- HONNAM
- COTULLA
- ALTON
- BOYD
- CRANDALL
• ALVORD
- HRACKEINILLE
- CRANE
- AMHERST
- BRADY
• CRANFlLLSGAP
• ANNONA
- BRAZORIA
- CRAWFORD
• ANTHONY
- BREMOND
• CROCKETI'
- ARANSASPASS
- BRENHAM
- CROWLEY
- ARLINGTON
- BRIDGE CITY
- CRYSTAL CITY
- ARP
- BRIDGEPORT
- CUERO
- ASHERTON
- BROWNSVILLE
• CUMBY
- ATLANTA
- BROWNWOOD
- CUSHING
- AUS'[WELL
- BRUCEVILLE - BDDY
• DAINGERFlELD
- AVFRy
- BRYSON
- DALLAS
- AVINGER
- BUDA
- DALWORTHINGTON GARDENS
- BAILEY
- BOLLARD
- DAWSON
- BALCH SPAINGS
• BURTON
• DECANR
- BALCONES HEIGHTS
- BYERS
- DEL RIO
- BALLINGER
- CADDO MILIS
- DELL CITY
- BANGS
- CALVERT
- DENISON
- BANQUEIE
- CARRIZOSPRINGS
- DENTON
- BpRRY
- CARROLLTON
- DEPORT
- BAY CITY
• CENTER
- DE50T0
- BAYSIDE
- CHATEAU WOODS
- DEIROIT
• BEARCREEK
- CHICO
- DEVINE
- BEASLEY
- CHILLICOTHE
- DIBOLL
- BEAUMONT
- CHINA GROVE
- DODD CITY
• BECKVILLECITY
- CLARKSVILLE(REDItIVER)
- DOMINO
- eEDFORD
- CLARKSVILLE CITY(GREGG)
• DONNA
- BEEVILLE
- CLINT
- DRISCOLL
• BELLEVUE
• CLUTE
- EARLY
• BELLMEAD
- COCKRELLHILL
- EAST MOUNTAIN
- BELLS
- COLEMAN
• EASTTAWAKONI
- BELLVILLE
- COLI.INSVILLE
- EASTON
- BEVERLY HILLS
- COMHFS
- ECTOR
- BIG LAKE
• COMMERCE
- EDCOUCH
- BIG SANDY (UPSHUR)
- COMO
- EDINBURG
- BISHOP
• CONROE
• EDNA
- BLANCO
- CONVERSE
- EL CAMPO
- HLANKET
- COOL(DGE
• EL PASO
- BLOOMBURG
- COOPER
• ELMENDORF
Feb 26, 2001 1 / 4
DELINQUENT TAX CLIENT LIST
CITIES REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PE1VA & SAMPSON LLP
- ELSA
- HAWKINS
- KOSSE
• EMHOUSE
- HEARNE
- KYLE
- EMORY
- HEATH
- LA FERIA
- ENCINAL
- HEMPHILL
• LA lOYA
' EULESS .
• HENDERSON
- LA PRYOR
- EVANT
• HENRIEITA
- LA VILLA
- EVERMAN
- HEWI7T
• LADONIA
- FAIRVIEW
- HICO
- LAGUNA VISTA
• FALFURRIAS
- HILLCOUNIRYVILLAGE
- LAKEPORT
- FALIS CITY
• HONEY GROVE
- LAKESIDE(SAN PATRICIO)
' FATE
- HORIZON
- LAMPASAS
- FLORESVILLE
- HOUSTON
• LANCASTER
• FORESTHILL
- HOWE
- LEFORS
- FORNEY
- HUDSON
• LEGGEIT
- FORTSTOCKTON
• HUGHESSPRINGS
- LEONARD
' FRANKLIN
- HUNTINGTON
• LEXINGTON
• FRANKSTON
- HUTCHINS
- LINDALH
- FRISCO
- INDIAN LAKE
• GPAN
- FROST
- INGLESIDE
- LITTLEF[ELD
• FULSHEAR
- INGLESIDE ON THE BAY
- LIVE OAK
- FULTON
• IREDELL
- GVINGSTON
• GANADO
• ITALY
• LLANO
• GARRISON
• lASPER
- LOCKHART
- GEORGE WFST
- IEFFERSON
- LOMETA
- GIDDINGS
- 1BRSEY VILLAGE
• LONE STAR
- GILMER
- IOAQUIN
- LONGVIEW
• GOLDSMITH
- )OHNSON CITY
• LOS FRESNOS
- GOLDTHWAITE
. JOSHUA
• LO'IT
- GONZALFS
•JOURDANTON
- LUCAS
- GOODRICH
- KARNFS CITY
- LUFKIN
- GRANBURY
- KAUFMAN
• LULING
- GRAND PRAIRIE
- KELLER
- LYFORD
- GRANDFALLS
_ KE,Np
- MABANK
- GMPELAND
• KENDLEI'ON
- MADISONVILLE
- GREENVILLE
- KENEDY
- MALAKOFF
- GREGORY
- KENNARD
- MANSflELD
- GREY FOREST
• KENNEDALE
- MARLIN
- GROVFS
- KERENS
- MARQUEZ
- GROVETON
_ KEgh{IT
- MART
• GUNTER
• KILGORE
- MAR77NDALE
- HAI.LEl75VILLE
• KINGSVILLE
- MASON
• HAMILTON
. KIRgy
- MATHIS
- HARLINGEN
- KIRBYVILLE
- MCALLEN
Feb 26, 2001 2/4
APPRAISAL DISTRICTS
REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIIi
GRAHAM PENA & SAMPSON LLP
. ANDERSON CAD
• KENDALL CAD
- UPTON CAD
. ANGEL[NA CAD
+KINNEY CAD
. VAN ZANDT CAD
. ARANSAS CAD
. LA SALLE CAD
. WALKER CAD
- AUSTIN CAD
LAMAR CAD
. WALLER CAD
. BANDERA CAD
LAMPASAS CAD
. WARD CAD
. HEE CAD
LAVACA COUNTY CAD
- WASHINGTON CAD
• BLANCO CAD
. LEE CAD
. WHARTON COUNTY CAD
- BROWN CAD
. LIHERTY CAD
. WILLACY CAD
-CALDWELL CAD
--LIVE OAK CAD
+WILSON CAD
. CAMERON AD
. MADISON CAD
. WINKLER CAD
CAMP CAD
. MARION CAD
- WiSE CAD
- CASS CAD
MASON CAD
. WOOD CAD
--CHEROKEE CAD
. MATAGORDA CAD
. ZAPATA CAD
+CLAY CAD
MCCULLOCH CAD
- ZAVALA CAD
- COLEMAN COUNTY TAD
. MCMULLEN CAD
. COMANCHE CAD
MILLS CAD
• COOKE CAD
. MONTAGUE CAD
. CRANE CAD
MORRIS CAD
- CULBERSON CAD
NAWGDOCHES COUNTY CAD
- DELTA CAD
NAVARRO CTO
. DENTON CAD
• NEWTON CAD
. DEWI7T CAD
. NUECES CAD
. DIMMR CAD
ORANGE CAD
. DUVAL CAD
PARKER CAD
--EASTLAND CAD
. PECOS CAD
FANNIN CAD
RAINS COUNTY TAD
' FRIO CAD
RED RIVER CAD
. GONZALFS CAD
. REEVFS CAD
. GRAY CAD
' ROBERTSON CAD
• GRAYSON CAD
--ROCKWALL CAD
- HAMILTON CAD
. RUNNELS CAD
• HAItRISON CAD
SAN PATRICIO CAD
- HOOD CAD
- SAN SABA COUNTY CAD
. HOPfUNS CAD
. SHELBY COUNTY TAD
- HOUSTON CAD
. SMITH CAD
- HUDSPETH AD
. STARR CAD
JACK CAD
. SU7TON CAD
. lACKSON CAD
TINS CAD
-IASPER CAD
--TOM GREEN CAD
. lIM HOGG CAD
. TRAVIS CAD
• JIM WELLS CAD
. 1RINITY CAD
• 10HNSON CAD
TYLER CAD
. KAUFMAN CAD
. UPSHUR CAD
. APPRAISAL ONLY
"COLLECfORONLY
APPR/COLL
Feb 26, 2001 + DTAX CLIENT ONLY ~
DELINQUENT TAX CLIENT LIST
COUNTIES REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PE1VA & SAMPSON LLP
- ANGELINA COUNTY
- ARANSAS COUNTY
- JEFFERSON COUNTY
- RUSK COUNTY
- ARCHER COUNTY
- 7IM HOGG COUNTY
- SABINE COUNTY
- AUSTIN COUNTY
- KARNES COUNTY
- SAN AUGUSTINE COUNTY
- BEE COUNTY
- KAUFMAN COUNTY
• SAN PATRICIO COUNTY
- BEXAR COUNTY
- KENEDY COUNTY
- SAN SABA COUNTY
- BLANW COUNTY
- KING COUNTY
- SHELBY COUNTY
- HROOKS COUNTY
- KINNEY COUNTY .
- SM[TH COUNTY
- BROWN COUNTY
- KLEBERG COUNTY
- STARR COUNTY
- CALDWELL COUNTY
- LA SALLE COUNTY
• TARRANT COUNTY
• CAMERON COUNTY
- LAMAR COUNTY
• TOM GREEN COUNTY
- CAMP COUNTY
• LAMB COUNTY
- TRINITY COUNTY
- CHAMBERSCOUNTY
- LAMPASASCOUNTY
- TYLERCOUNTY
- CLAY COUNTY
- LAVACA COUNTY
• UPSHUR COUNTY
- COLEMAN COUNTY
- LEE COONTY
• UP'I'ON COUNTY
- CMNE COUNTY
• LIMFSTONE COUNTY
- VAL.VERDE COUNTY
- CULBERSON COUNTY
- LIVE OAK COUNTY
- VICTORIA COUNTY
- DALLASCOUNTY
• LLANOCOUNTY
- WALLERCOUNTY
- DELTA COUNTY
- LOVING COUNTY
- WARp COUNTY
- DEWITf COUNN
• MADISON COUNTY
- WASHINGTON COUNTY
- DIMMIT COUNTY
- MARION COUNTY
- WHARTON COUNTY
- DUVALCOUNTY
• MASONCOUNTY
- WILLACYCOUNTY
- ECTOR COUNTY
- MATAGORDA COUNTY
- WILSON COUNTY
- EL PASO COUNTY
- MCCULLOCH COUNTY
• W[NKLER COUNTY
- ELLIS COUNTY
- MCLENNAN COUNTY
- WISE COUNTY
- FALLS COUNTY
- MCMULLEN COUNTY
- WOOD COUNTY
• FANNIN COUNTY
- MILLS COUNTY
- ZAPATA COUNTY
- PORT BEND COUNTY
- MONTAGUE COUNTY
• ZpVpLA COUNTY
• FRIO COUNTY
- MONTGOMERY COUNTY
- GONZALES COUNTY
• MORRIS COUNTY
- GRAY COUNTY
• NACOGDOCHES COUNTY
- GRAYSON COUNTY
• NAVARRO COUNTY
• GREGG COUNTY
. • NUECFS COUNTY
- HAMILTON COUNTY
- ORANGE COUNTY
- HARRIS COUNTY
- PARKER COUNTY
- HIDALGO COUNTY
- PECOS COUNTY
• ROOD COUNTY
• POLK COUNTY
- HOPKINS COUNTY
- RAINS COUNTY
- HUDSPEfH COUNTY
- REAGAN COUNTY
- HUNT WUNTY
• RED RNER COUNTY
- IACK COUNTY
• REEVFS COUNTY
• JACKSON COUNTY
- REFUGIO COUNTY
- JASPERCOUNTY
- ROBERTSON COUNTY
- lEFF DAVIS COUNTY
- ROCKWALL COUNTY
Feb 26, 2001 ~ ~ ~
DELINQUENT TAX CLIENT LIST
CITIES REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP
- PALM VALLEY
- ROBSTOWN
• MCCAMEY
- MCLEAN
- PALMER
- ROCKPORT
- PALMVIEW
- ROCKWALL
- MEGARGEL
• PAMPA
- ROCKY MOUND
- MELVIN
- MERCEDFS
• PANTEGO
- ROMA
- MERIDIAN
- PARADISE
• ROSE CITY
- pATfON VILLAGE
- ROSEBUD
MEXIA
- PEARLAND
- ROUND ROCK
- MIDIATHIAN
- PEARSALL
- ROYSE CITY
- MILFORD
- PECAN GAP
- RUNAWAY BAY
• MONAHANS
- MONTBELVIEU
- PECAN HILL
- RUNGE
- PEC0.S CITY
' RUSK
• MOODY
- PETROLIA
- SAN ANGELO
- MORGAN
• PHARR
- SAN ANTONIO
- MOULTON
- PHILADELPHIA (PA)
- SAN AUGUSTINe
• MT ENTEBPRISE
• PINE FOREST
- SAN BENITO
- MULLIN
- MUSTANG RIDGE
- PINEHURST
- SANlUAN
- PINELAND
- SAN PERLITA
- NACOGDOCHES
- PI7TSBURG
SANSABA
-
- NAPLES
- PLEASANTON
- SANSOM PARK
- NASSAU BAY
- POINT
- SANTA ANNA
• NATALIA
- PORT ARANSAS
- SANTA ROSA
• NEDERLAND
• NEEDVILLE
- PORTARTHUR
- SAVOY
• NEW BRAUNFEIS
- PORTISABEL
• SEABROOK
- PORTLAND
- SEAGOVILLE
- NEW LONDON
- POTH
• SEALY
• NEWARK
- SHAVANO PARK
• NIXON
• POTTSBORO
- PRIMERA
- SHENANDOAH
- NORDHEIM
- PROGRESO
• SHERMAN
- NORMANGEE
- NORTH RICHLAND HILLS
- PROSPER
- SHINER
- QUEEN CI7Y
- SINTON
- NOVICE
- QUINLAN
- SMILEY
• OAK LEAF
- RANISIN
SOCORRO
-
- OAK RIDGE
'
- RAYMONDVILLE
- SOMERSEI
- OAK RIDGE NORTH
- RED OAK
. SOUTH HOUSTON
ODEM
-
- SOUTH PADRE (SLAND
- OMAHA
- RENO
• RHOME
• SOUTNMAYD
- ONALASKA
- RICE
• SPLENDORA
- ORANGE
- ORANGE GROVE
- RICHLAND
- SPOFFORD
- RICHLAND SPRINGS
• SPRINGLAKE
- ORCHARD
- SPRINGTOWN
- ORECITY
- RICHMOND
- RIOVISTA
- STHEDWIG
- OVERTON
- STARHARBOR
• PALACIOS
- ROBINSON
3!4
Feb 26, 2001
DELINQUENT TAX CLIENT LIST
CITIES REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP
- STEPHENVILLB
- STOCKDALE
- SULPHUR SPRINGS
- SUNRISE 6EACH VILLAGE
- iAFT
- TALCO
• TEHUACANA
- TENAHA
• TERRELL
- 7'ERRELL HILLS
• THORNTON
- 7HREE RIVERS
- TIMPSON
- 770GA
- TOLAR
- TOM BEAN
- TOYAH
• 7RENTON
- 7RINITY
- TROUP
- TYLER
- UNIVERSAL CITY
- VAN HORN
- VICTORIA
- VIDOR
- WAELDER
- WALLIS
- WALNUTSPRINGS
- WAXAHACHIE
- WEATHERFORD
• WELLS
- WFST
• WESTORANGE
- WFS7HROOK
- WHARTON
- WHITEOAK
• WNITESEITLEMENT
- WHIIEHOUSE
- WICKEIT
• WILLOWPARK
• WILMER
- WINDOM
- WINK
- WINNSBORO
• WINONA
- WOODBRANCH VILLAGE
- WOODSBORO
- WOODVILLE
- WOODWAY
- YANTIS
- YOAKUM
- YORKTOWN
Feb 26, 2001
4 , 4
DELINQUENT TAX CLIENT LIST
ENDENT SCHOOL DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP
- AGUA DULCE ISD
• ALAMO HEIGHTS ISD
• BREMOND ISD
- CLARKSVILLE ISD
- ALBA - GOLDEN ISD
- BRENHAM ISD
- CLINT ISD
- ALEDO ISD
- BRIDGE CITY ISD
- COANOMA ISD
- ALTO ISD
- BRIDGEPORT ISD
- COLEMAN ISD
- ALVARADO ISD
- BROADDUS ISD
- COLLMSVILLE ISD
- ALVORD ISD
- BROCK ISD
- COLMESNF]L ISD
- AMHERSTISD
- BROOKELANDISD
- COLUMB[A-BRAZORIAISD
- ANTHONY ISD
- BROOKESMTTH ISD
• COMMUNI7Y ISD
- APPLE SPRINGS ISD
- BROOKS W[SD
- COMSTOCK C[SD
- ARANSAS CO ISD
- BROWNSBORO ISD
- CONNALLY ISD
- ARANSAS PASS ISD
• BROWNSVILLEISD
• CONROEfSD
- ARPISD
- BROWNWOODISD
- COOLIDGEISD
• ATLANTA ISD
- BRUCEVILCE • EDDY ISD
• COOPER ISD
- AUSTWELL - TTVOLI ISD
- BRYSON ISD
- CORPUS CHRIST[ ISD
• AVERY ISD
- BUENA VISTA ISD
• CORSICANA ISD
• AVINGER ISD
- BULLARD ISD
• CONLLA ISD
- AX7ELL ISD
- BUNA ISD
- CRANDALL ISD
- BANGS ISD
• BURKEVILLE ISD
- CRANE ISD
- BANQUETE ISD
- BURTON [SD
- CRANF[LLS GAP ISD
- BAY CITY ISD
- BYERS ISD
- CMWFORD 1SD
- BEAUMONT ISD
- CADDO MiLIS ISD
- CROCKEIT ISD
- BEEV[lLBISD
- CALALLEN ISD
- CROWLEY ISD
• BELIS ISD
- CALVERT ISD
- CRYSTAL CI"fY ISD
• BELLVILLE ISD
- CANU77LL0 ISD
- CUERO ISD
- BEN BOLT • PALITO BLANCO ISD
- CARI.ISLE ISD
- CULBERSON CO - ALLAMOORE ISD
- BENAVIDFS ISD
- CAYUGA ISD
- CUMBY ISD
• BIG SANDY ISD (POLK)
- CENTER ISD
• CUSHING ISO
- BIG SANDY ISD (UPSHUR)
• CENTERVILLH ISD (TRINI'1'Y)
- CYPRFSS - FAIRBANKS ISD
- BIRDVILLE ISD
- CEN7RAL HEIGHTS ISD
• DAINGERFlEID - LONE STAR ISD
- BISHOP CISD
- CEN7RAL ISD
- DALLAS ISD
• BLANCO ISD
- CHAMBERS CO SCHOOL EQUAL
- DAWSON ISD
- BLAND ISD
• CHAPEL HILL ISD
- DECANR ISD
- BLANKEI' iSD
- CHARLOTTE ISD
- DEER PARK ISD
• BLOOMHURG ISD
- CHEROKEE ISD
• DELL CIT' ISD
- BLOOMING GROVE ISD
- CHESTER ISD
- DENISON ISD
- 9IAOMINGTON ISD
- CHICO ISD
• DEfIlOIT [SD
• BLUPF DALE ISD
- CHILLICOTHE ISD
- DEWEriILLE ISD
- BOERNE ISD
• CH[LTON ISD
- DIBOLL ISD
- BOLING ISD
• CHINA SPRING ISD
- DIME BOX ISD
• BOYD ISD
- CHIRENO ISD
- DODD CI7Y 1SD
- BRACKETI' ISD
• CHISUM ISD
- DONNA ISD
- BMDY ISD
- CHRISTOVAL ISD
• DOUGLASS ISD
- BRAZOSISD
- C6COISD
- DRISWLLISD
Feb 26, 2001 1 / 4
DELINQUENT TAX CLIENT LIST
INDEPENDENT SCHOOL DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SfA2"SON LLP
- DUNCANVILLE ISD
- GONZALES ISD
- 10AQUIN ISD
- DUVAL CO VOCA770NAL DIST
- GOODRICH ISD
- 10HNSON CITY ISD
- EARLY ISD
- GRANBURY ISD
- KARNFS CITY ISD
- EAST BERNARD ISD
- GRAND PRAIRIE ISD
- KATY ISD
- EAST CEN7RAL ISD
• GRANDFALIS - ROYALTY ISD
• KAUFMAN 15D
- ECTORISD
- GRANDVIEW - HOPKINSISD
- KELLERISD
• EDCOUCH - ELSA ISD
• GRAPE CREEK ISD
- KEMP ISD
- EDGEWOOD ISD (BIXAR)
- GRAPELAND ISD
• KENDLETON ISD
- EDINHURG CISD
- GREEN WOOD ISD
- KENEDY COUNTYWIDE ISD
- EDNAISD
- GREGORY - PORTLANDISD
- KENNARDISD
- EL CAMPO ISD
- GROVETON ISD
- KENNEDALE ISD
- EL PASO ISD
- GUTHRIE CSD
- KERENS ISD
- ELYSfAN FlELDSISD
• HALLEITSVILL2ISD
• KERMITISD
- ERA ISD
- HAMILTON ISD
- KILGORE ISD
- EI'OILEISD
- NAMSHIRE - FANNETfISD
- KINGSVILLEISD
- EUSTACEISD
- HARLANDALEISD
- KIRBYVILLEISD
- EVADALE ISD
• HARLINGEN CISD
- LA FER1A ISD
- EXCELSIOR ISD
- HARMONY ISD
- LA JOYA ISD
• EZZELL [SD
- HAWKINS ISD
• LA PRYOR ISD
• FABENS ISD
- HAYS CISD
- LA VERNIA ISD
- FALLS CI'CY ISD
- HEARNE ISD
- LA VILLA ISD
- FANNINDEL ISD
- HEMPHILL ISD
- LAKE WORTH ISD
- FERRIS ISD
- HENDERSON ISD
• LAMAR CISD
- FLORENCEISD
• HENRIEITAISD
- LAMPASASISD
• FLORESVILLHiSD
• HICOISD
• LANCASTERISD
- FLOUR BLUFF ISD
- HOLLIDAYISD
• LANEVILLEISD
• FORESTBURGISD
• HONEY GROVECISD
- LASARAISD
- FORNEYISD
- HOUSTONISD
• LATEXOISD
- FORTBENDISD
- HOWEISD
- LEFORSISD
- FORT DAVIS ISD
- HOCKABAY ISD
- LEGGEIT ISD
- FORT HANCOCK ISD
- FiUD50N ISD
- LEONARD ISD
- FORT STOCKTON ISD
• HUGHFS SPRINGS ISD
- LEVERETTS CHAPEL ISD
- FRANKLIN ISD
- HUMBLE ISD
- LEXINGTON ISD
- FRANKSTON ISD
• HUNTINGTON ISD
- LINDALE ISD
- PREER ISD
- HORST- EULESS • BEDFORD ISD
- LINDEN - KILDARE CISD
- GANADO ISD
- INDUSTRIAL ISD
- LINGLEVILLE ISD
• GARNER ISD
- INGRAM ISD
- LIPAN ISD
- GARRISON ISD
- IREDELL ISD
- LI7TLE CYPRESS - MAURICEVILLE CISD
- GEORGE WEST ISD
- ITALY ISD
- LITI'LEFIELD ISD
- GHOLSON ISD
- JACKSBORO ISD
- LIVINGSTON ISD
• GIDDINGS ISD
- IACKSONVILLE ISD
- LLANO ISD
• GILMERISD
• IASPERISD
• LOCKHARTISD
- GOLDTHWAITE ISD
- lIM HOGG W ISD
- LOHN ISD
Fe6 26, 2001 2/ 4
DELINQUENT TAX CLIENT LIST
INDEPENDENT SCHOOL DISTRICTS REPRESENTED BY
LINEBARGER FIEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP
• IAMEI'A ISD
• MORGAN ISD
- pHARR-SAN IUAN-ALAMO ISD
- LONDON ISD
- MORGAN MILL ISD
- PITlSeURG ISD
- LONE OAK ISD
• MOULTON ISD
- PLEASANTON ISD
- IARENA ISD
- MOUNT VERNON ISD
- POINT ISABEL ISD
• IAS FRESNOS CISD
- MT ENTERPRISE ISD
• PppLVILLE ISD
- LOUISE ISD
- MULLIN ISD
- PORT ARANSAS ISD
- LOVFJOYfSD
- MUMFORDISD
• PORTARTHURlSD
- IAVELADY ISD
• NACOGDOCHES ISD
• PORT NECHES - GROVES ISD
- LUFKIN ISD
- NEDERLAND ISD
- POTH ISD
- LUL(NG ISD
- NEEDVILLE ISD
- PRAIRIE LEA ISD
- LYFORD CISD
- NEW BRAUNFEIS ISD
• PRAIRILAND ISD
- MAHANK ISD
- NEW DIANA ISD
- PREMONT ISD
• MADISONVILLE CISD
• NEW SUMMERFIELD ISD
- PRIDDY ISD
• MALAKOFF iSD
- NIXON • SMII.EY CISD
- PROSPER ISD
• MARIEITA CISD
- NORDHEIM ISD
• QUEEN CITY ISD
- MARLIN ISD
- NORMANGEE ISD
- QUINLAN ISD
- MART ISD
- NORTH EAST ISD
• RA[NS ISD
- MARTINSVILLE ISD
• NORTH FORFST ISD
• RAMIREZ COMMON SCH DIST
- MASON ISD
- NORTH HOPKINS ISD
- RANKIN ISD
- MATAGORDA ISD
- NORTH LAMAR ISD
- RAYMONDVILLE ISD
- MATHIS ISD
- NORTH ZULCH ISD
- REAGAN CO ISD
- MAY ISD
- NORTHSIDF.ISD (BEXAR)
- RED OAK ISD
- MCALLEN ISD
• NOVICE ISD
- REFUGIO ISD
• MCCAMEY ISD
- NURSERY ISD
- RICARDO ISD
- MCFADDEN ISD
- ODEM-EDROY ISD
• RICE ISD
- MCLEAN ISD
- ONALASKA ISD
- RICHLAND SPRINGS ISD
• MCLEOD ISD
- ORANGE GROVE ISD
- RIESEL ISD
- MCMULLEN CO ISD
- ORANGEPfELD ISD
- RIO GRANDE CITY CISD
- MEDINA ISD
- ORE CITY ISD
• RIO HONDO ISD
• MEGARGEL ISD
• OVERTON ISD
- RIVERCRFST ISD (TALCO-BOGATA CISD)
- MELISSA ISD
- PALACfO5 ISD
- ROBMSON ISD
• MERCEDES ISD
- PAMPA ISD
- ROBSTOWN ISD
• MERIDIAN ]SD
- PANTHER CREEK CISD
• ROCHELLE ISD
- MEYERSVILLE ISD
- PARqDISE ISD
• ROCKWALL ISD
- MfDLOTHIAN ISD
- PARIS ISD
• ROMA ISD
- MIDWAYISD
- PAWNEEISD
• ROSEBUD-L0ITISD
- MILDRED ISD
- PEARSALL ISD
• ROUND ROCK ISD ,
- MILFORD ISD
- PEASTER ISD
- ROXTON ISD
• MILLER GROVE ISD
- PECOS - BARSTOW - TOYAH ISD
- ROYSE CITY ISD
• MILISAP ISD
- PERRIN - WHITT CISD
- RUNGE ISD
• MONAHANS • WICKETT- PYOTE ISD
- PEfItOLIA ISD
- RUSK ISD
• MONTE ALTO ISD
• PEITIJS ISD
- SABINE ISD
- MONTGOMERY ISD
- PEWI7T ISD
• SALTILLO ISD
Feb 26, 2001 3/4
DELINQUENT TAX CLIENT LIST
INDEPENDENT SCAOOL DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIIt
GRAHAM PE1VA & SAMPSON LLP
- SAM RAYBURN ISD
• TANM ISD
- WILLIS ISD
- SAN ANGELO 1SD
• TAYIAR ISD
- WIMBERLEY ISD
• SAN ANTONIO ISD
• TENAHA ISD
- WINK - LOVINC ISD
- SAN AUGUS77NEiSD
- TERRELLISD
- WINNSBOROISD
- SAN DIEGO ISD
- THREE RIVERS ISD
- WINONA ISD
- SAN ELIZARIO ISD
- TIDEHAVEN ISD
- WODEN ISD
- SAN IS(DRO ISD
- TIMPSON ISD
- WOLFE C17Y ISD
- SAN MARCOS CISD
- TOLAR ISD
- WOODSBORO ISD
• SAN PERLRA ISD
- TORNILLO ISD
- WOODVILLB ISD
- SAN SABA ISD
- TRENTON ISD
- YANTIS ISD
• SANTA ANNA ISD
- TR[NITY ISD
- YOAKUM ISD
- SANTA GER7RUDIS ISD
- TROUP ISD
- YORKTOWN ISD
• SANTA MARIA ISD
- NIASO - MIDWAY ISD
- YSLEfA iSD
- SANTA ROSA ISD
- TYLER ISD
- ZAPATA CO ISD
- SAVOY ISD
- UNION GROVE ISD
- ZAVALLA ISD
- SCURRY - RQSSER ISD
- UNION HILL ISD
- ZEPHYR ISD
• SEALY ISD
• VALLEl VIEW ISD
- SHARYLAND ISD
- VAN AISTYNE ISD
- SHELBYVILLE ISD
- VAN VLECK ISD
- SHERMAN ISD
- VERIBEST ISD
- SHINER ISD
- VICTORIA ISD
- SIERRA BLANCA ISD
• VIDOR ISD
- SIN70N ISD
- VYSEHItAD ISD
- SKIDMORE•TYNANISD
- WAELDERISD
- SLIDELLISD
- WALIISD
- SLOCUM ISD
- WALNUT SPRINGS ISD
- SOCORRO ISD
- WARREN ISD
- SOMERSEf ISD
- WATER VALLEY ISD
- SOUTH SAN ANTON[0 [SD
- WEATHERFORD ISD
• SOUTH TEXAS ISD
- WEBB CISD
- SOUTHSIDE ISD
- WEUS ISD
• SPADEISD
• WFSLACOISD
- SPRING NILL ISD
- WFST ISD
- SPRINGTOWNISD
• WFSTORANGE - COVECISD
- SPURGER ISD
- WEST OSO ISD
- STAA ISD
• W FST RUSK CO CISD
- STEPRENVILLE ISD
- WFST SABINE ISD
- STOCKDALE ISD
- WFSTBROOK ISD
- SULPHUR BLUFF iSD
- WESTHOFF ISD
- SULPHUR SPRINGS ISD
- WESTPHALIA ISD
• SWEEPHOMEISD
- WHARTONISD
- TAFf ISD
• WHITEHOUSE ISD
• TARKINGTON ISD
- WHITESBORO ISD
Pob 26, 2001 4 / 4
DELINQUENT TAX CLIENT LIST
SPECIAL TAXIIVG DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIIt
GRAHAM PENA & SAMPSON LLP
- ACTON MUD
• ALAMO COMM COLL DIST
• CISCO 1C
- FALLS CO FD X 03
- ANDERSON MILL MUD
- CLAPP RD
• FALIS CO WCID M 01
• ANGELINA CO FWD
- CLAY COUNTY FD M 01
• FANNIN CO WTR AUTHORITY
- ANGELINA COLLEGE DIST
- CLAY COUNTY FD d 02
- FARMER'S CREEK WD
- ARANSAS CO MUD M 01
• CLEAR CREEK WD
- FERRIS FD
- ARANSAS CO ND N Ol
- CLEAR CREEK WTRSHD DIST
- FORT BEND CO MUD N 26
- AUDS CREEK WD
- COASTAL BHND COLL (BHE CO COLL)
- FORT BEND CO RFD N 01
- AUSTIN CO RFD N 03
- COLEMAN HD
- FORT BEND CO RFD M 02
- BEACH RD MUD
- COMMERCE WD
- FORT BEND CO WCID M 03
- BEAUMONT NAV DIST
- CORPUS CHRISTI DOWNTOWN MGMT
- FORT BEND PARKWAY RD
- BEE CO FPD M 03
• CRANE CO WD
• FORT CLARK SPRGS MUD
- BEEVILLE WATER SUPPLY DIST
• COERO HD
- FORT HANCOCK WCID d 01
- BEVIL OAKS MUD
- CULBERSON CO HOSP DIST
• FRED FIRE DIST
- BEXAR CO HD (UNIV HLTH SYSTEM1n
- CULBERSON GWCD
• FRIO HD
- BEXAR W RD DIST # 01
- CUMMINS CREEK WCID N 01
- GONZALES CO EMSD M Ol
- BEXAR CO RD DIST M 02
- DALLAS CO HD (PARKLAND)
- GONZALFS CO FD
• HEXAR CO RD D[ST N OJ
- DALLAS COMM COLL DIST
- GONZALFS HEALTHCARE
• BEXAR CO RD DIST N 04
- DEL MAR COLLEGE
- GONZALES WD
- BEXAR CO WTR DIST N 17
- DELTA CO EMG N OI
- GRAY COUNTY WD
- BI STONE MUNICIPAL WSD
- DELTA COUNTY MUD
- GRAYSON CO 1R COLLEGE
- BLACKIACK RD DIST
- DENTON CO W D N Ol
- GREATER EAST END MGMT DIST
• BLANCO CO FSD
- DEwITT CO MEDICAL DIST
- GREGG CO RURAL FPD N Ol
- BLANCO FIRE DIST
- DOUGLASS F1RE PREV # 03
- HACIENDA DEL NORTE WD
- BLINN 1R CDLLEGE
- DUVAL CO CONSV RECLAM DIST
- HAMILTON HD
- BOLING MWD
- DUVAL CO FSD M Ol
- HARRIS - FORT BEND FSD X 100
- BONHAM WATER AUTHORITY
- DUVAL CO WD
- HARRIS CO FSD M 01
- BRISTOL FD
• ECLETO CRHEK WATERSF[ED AUTHORITY
- HARR[S CO ESD N 02
- BROWN CO WID A OI
- EDWARDS UWD
- HARRIS CO ESD # 07
- BROWNSVILLE I& DD
• EL PASO CO RFPD p 1(FSD N 2)
- HARRIS CO FSD M 04
• eROWNSVILIE NAV DIST
- EL PASO CO WTR AUTHORITY
- HARRIS CO ESD N OS
• BRUSITY CREEK MUD
• EL PASO COMM COLL
• HARRIS CO ESD N 07
- CAMERON CO DRAIN DIST d 01
• EL PASO COUNTY WID N 01
- HARRIS CO ESD N 09
- CAMERON CO DRAIN DIST N 03
- EL PASO DWNTWN MGMT DIST
- HARRIS CO FSD N 26
• CAMERON CO DRAIN DIST N 04
- ELLIS CO FD M 09
- HARRIS CO FCD
- CAMERON CO DRAIN DIST M OS
- ELLIS CO FD N 10
- HARRIS CO HD
- CAMERON W EMER SERVS DIST
• ELM CREEK WTR SHED
- HARRIS W ID M Ol
- CANEY CREEK MUD
- EMERALD BAY MUD
- HARRIS CO MUD M 43
- CENTRAL FPD
- ENGELMAN ID N 06
- HARRIS CO MUD N 30
- CHAMBERS CO HD (BAYSIDE COMMUNITY
- ESCONDIDO WD
- HARRIS CO RFPD N Ol
HOSP)
- EVERGREEN UWCD
- HARRIS CO RFPD N 06
• CHAMBERS-LIBERTY COUNTIFS ND
• FAfRWAY BEND IMPROV DIST
- HAIWS CO RFPD N OB
• CHATEAU WOODS MUD
• FALLS CO FD N 01
- HARRIS W RFPD # 10
• CHOCTAW WD
- FALLS CO FD N 02
• HARRIS W RFPD N 13
Feb 26. 2001 1 / 4
DELINQUENT TAX CLIENT LIST
SPECIAL TAIIING DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP
• HARRIS CO RFPD / 16
- HARRIS CO RFPD p 17
- HARRIS CO RFPD N 19
- HARRIS CO RFPD X 20
• HARRIS CO RFPD Y 21
- HARRIS CO RFPD N 24
- HARRIS CO RFPD N 25
- HARRIS CO RFPD M 29
- HARRIS CO RFPD N 47
- HARRIS CO RFPD N 48
- HARRIS CO SCHOOL EQUAL
- HARRIS CO WCID A 21
- HICKOAY UWCD R 01
• HICO EMS DIST
- HIDALGO CO DRAIN DIST A 01
- HIDALGO CO FD M 01
- HIDALGO CO FD M 02
- HIDALGO CO FD M 03
- HIDALGO W FD X 04
• H[DALGO CO 1RRIG DIST M OI
- HIDALGO CO IRRIG DIST X 06
- HIDALGO CO IRRIG DIST k 16
- HIDALGO CO RD 8 OS
- HOMFSTEAD MUD N 02
- HONDO WD
- HOOD CO HD
• HOOD CO LIBRARY
• HOPKINS CO HD
- HORIZON RFPD N 1(ESD N 1)
- HOUSTON COMM COLL
- HOUSTON DWNTWN MGMT DIST
• HUDSPE7ti CO ESD X Ol
- HUDSPEI'F[ CO UWCD
- HUNGERFORD MUD N 01
- INGLFSIDE INDUS7RIAL
- ISAACSON MUD
- ITALY FD
- IVANHOE VFD N 02
- IACK CO HD
- IACK CO WCID M 01
- IACKCOUNTYE.K.W.D.
• IACKSON CO DRA1N DIST M OI
- IACKSON CO DRAIN DIST M 02
- JACKSON CO FLOOD DIST
- IACKSON CO HD
- JACKSON CO RFD
- IACKSON CO WCID / 1(LOLITA WD)
• IACKSON CO WCID # 2(VANDBRBILT WD)
- JASPER CO WCID N 01
- JEFFERSON CO DD N 03
• IEFFERSON CO DD N 06
- IEFFERSON CO DD MW
- IEFFERSON CO FSD
• ]EFFERSON CO RFPD M 01
- IEFFERSON CO WCID A 10
- KARNES CO FD
• KARNFS CO HD
• KAUFMAN RURAL flRE DIST M 01
- KEMP RURAL FIRE DIST X 04
- KILGORE COLLEGE
- KINGSLAND MUD
- KOTHMAN RD DIST
- LA FERIA fRR[G DIST M 03
- LAGUNA MADRE WD
- LAKE LBl MUD
- LANGFORD CREEK MUD
- LAVACA - NAVIDAD RIVER AUTH
- LAVACA CO FLOOD DIST
- LAVACA HOSP DIST
- LEECOUNTYFWD
- LIBERTY-DANVILLE FWSD M 02
- LIPAN/KICKAPOO WCD
- LIVEOAKUWCD
- LLANO W FD X Ol
• LLANO CO FD / 02
- LLANO W FM ROAD
- LLANO CO MUD M Ol
- LLANO CO RD DIST N Ol (INKS)
- LLANO KINGSLAND MUD
- LOGANS-SLOUGH WD
- LOVING CO WID M 01
- LOWER VALLEY WT2 AUTH
- MABANK RURAL FlRE DIST N 02
- MARION CO HD
- MARKHAM MUD
- MATAGORDA CO CONSV & RECL DIST
- MATAGORDA CO DRAIN DIST N 01
- MATAGORDA CO DRAIN DIST X 02
- MATAGORDA CO DRAIN DIST N 03
- MATAGORDA CO DRAIN DIST M 04
- MATAGORDA W HOSP DIST
- MATAGORDA CO NAV DIST N 01
- MATAGORDA CO WCID N 02
• MATAGORDA CO WCID X S(BLESSING)
• MATAGORDA CO WC[D M 6(VAN VLECIQ
- MAYPEARLFD
- MCALLEN DOWNTOWN IMPRVMTTAX
- MCCAMEY FIRE DIST
• MCCAMEY HOSP DIST
- MCCULLOCH CO HOSP DIST
- MCLENNAN CO WCD A 02
- MCLENNAN COMM COLL
- MCLENNAN HILL TEHUACANA CO WCD A 01
- MCMULLEN CO WATER
- MEMORIAI. POINT (1D
- MIDLOTHIAN FD
• MIDLOTHIAN WCD
- MILLS CO SPEC RD & BRIDGE
- MIL1S CO WD F 01
- MONTGOMERY CO DD M 06
- MONTGOMERY CO ESD M 01
- MONTGOMERY CO ESD k 02
- MONTGOMERY CO ESD N 03
- MON7GOMERY CO FSD p 04
- MONTGOMERY CO FSD A05
• MONTGOMERY CO ESD M 06
- MONTGOMERY CO FSD M 07
- MONTGOMERY CO FSD M OS
- MONTGOMERY CO FSD X 09
- MONTGOMERY CO FSD M 10
- MONTGOMERY CO ESD X 11
- MONTGOMERY CO ESD A 12
- MONTGOMERY CO FSD M 14
~
- MONTGOMERY CO FD M OI
- MONTGOMHRY CO FD N 12
- MONTGOMERY CO FD M 14
- MONTGOMERY CO HD
- MONTGOMHRY CO MUD N OS
• MONTGOMERY CO MUD N 09
Feb 26, 2001
2 / 4
DELINQUENT TAX CLIENT LIST
SPECIAL TAXING DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP
- MONTGOMERY CO UD f 03
- PAWNEE FPD
- SEALY FD
• MONTGOMERY CO UD N 04
- PEITUS MUD
• SHELDON ROAD MUD
• MORRIS CO HD
- PINE CREEK WD
- SM1TH CO RFPD M Ol
- MOULTON COMM MED CUNIC
• PLUM CREEK CONS DIST
- SMITN CO WD 1' Ol
- N HARRIS-MONTGOMERY COMM COLL DIST
- POLK COUNTY FWD N 02
- SOUTH MONTGOMERY CO RD DIST M Ol
- NACOGDOCHES CO FIRE DIST
• PORT MANSFlELD UD
- SOUTH'fEXAS WTR AUTH
- NACOGDOCHFS CO HOSP DIST
- PORT OP BAY CITY AUTH
- SOUTH TX COMM WLL (STARIq
- NACOGDOCHES CO MUD k 01
- PORT OF BEAUMONT AOTH
• SOUTH TX COMM COLL(HIDALGO)
- NACOGDOCHES CO RD X 03
- PORT OF CORPUS CHRISTT
- SOUTHERN MONTGOMERY CO MUD
- NAVARAO COLLEGE
- PORT OF HARLINGEN
- SOUTHWEST TX ]R COLL DIST
- NEW CANEY MUD
• PORT OF HOUSTON AUTH
• SPRINGTOWN FlRE DIST M Ot
- NIXON HOSP DIST
• PORT OP PORT ARTHUR AUTH
- SPURGER FD M 01
- NORTH BEE CO FPD
- PORTER MUD
• TAFf HD
- NOHTHEAST TX COMM COLL DIST (CAMP)
- PRESIDENTS PARK RD DIST
- TARRAN7 CO FSD
- NORTHEAST TX COMM COLL DIST
• QUAIL CREEK MUD
• TARRANT CO FWSD N 01
(MORRIS)
- R E THOMASON HOSP DIST
• TARRANT CO HD
• NOATHEAST TX COMM COLL DIST (TITUS)
- RAINS COUNTY FD
- TARRANT CO JR COLL
- NORTHWEST FOREST MUD
• RANKIN FD
- TARRANT CO REG WTR DIST
- NUECFS CO DRA1N DiST M 2(RKP'q
• RANKIN HD
- TARRANT CO RFD
- NUECES CO DRAIN DIST R 3(BISHOP)
- RAYBURN COUN7RY MUD
- TERRELL RURAL FIRE DIST N 03
- NUECES CO FPD M 01
- REAGAN CO ND
- TEXAS SOUTHM0.ST COLLEGE
- NUECES CO FPD X 02
- REAGAN CO RD DIST
- TOM GREEN CO RFPD p Ol
• NUECFS CO FPD M 03
• REAGAN CO WSD
- TORNILLO WD
- NUECFS W FPD N 04
- RED CREEK WUD
- TRINITY BAY CONS DIST
- NUECFS CO FPD A05
- RED OAK FD
- 7RINITY MEMORIAL HD
• NUECES CO HOSP DIST
- RED RIVER CO WD
- 7RINITY VALLEY COMM COLL DIST
• NUECFS CO WCID N 4(PA)
• REEVES CO HD
• TYLER CO DAM B FD
- NUECFS CO WICD M 5(9ANQ)
• REFUGIO CO DRAIN DIST M 01
• TYLER CO HOSP DIST
- OAK HILLS DEVELOPMENT RD DIST
- REFUGIO CO MEMORIAL HD
- TYLER JC
- OAK RIDGE MUD
- REFUGIO CO WCID N 02
• UPPER SABINE WASTE DISP DIST
- ORANGE CO DRAINAGE DIST
- RUSK CO FPD 8 Ol
- UPSHUR CO FD N 01
- ORANGE CO EMG DIST X 01
• SABINE CO HD
• UPTON CO WD
- ORANGE CO EMG DIST M 02
• SABINE PASS PORT AUTH
- VAL VERDE CO HOSP DIST
- ORANGE CO FD Y 03
- SAN ANTONIO MUD M 01
• VICTORIA CO DD Y 02
- OMNGE CO FD M 04
- SAN ANTONIO RIVER AUTH
- VICTORiA CO DD X 03
- ORANGE CO NAV & PORT DIST
• SAN AUGUSTINE CO HOSP DIST
-VICTORIA CO DD N 04
- ORANGE CO WCID X 01
• SAN FELIPE FD
- VICfORIA CO NVD
- ORANGE CO WCID M 03
- SAN PATRICIO CO DRAIN DIST
• VICTORIA CO WD M Ol
• PAWCIOS SEAWALL COM
- SAN PA7RICI0 CO NAV
- VICTORIA CO WD X 02
- PARIS 1R COLL DIST
- SANTA CRUZ IRRIG DIST N IS
- VICTORIA IR COLLEGE DIST
• PARK CENTRAL MUD
- SANTA MARIA IRRG DIST N 04
- WARD CO WID 9 02
- PARKER CO HD
• SANTA RITA UWCD
- WARREN FD Y 04
• PARKER CO UD
- SCURRY - ROSSER FD M OS
- WAXAHACHIE FD
Feb 26, 2001 3 / 4
DELINQUENT TAX CLIENT LIST
SPECIAL TAIIING DISTRICTS REPRESENTED BY
LINEBARGER HEARD GOGGAN BLAIR
GRAHAM PENA & SAMPSON LLP ,
- WAXAHACHIHWATERDIST
• WEATHERFORD 1R COLL DIST
• WFST WNARTON COUNTY HD
- WESTCHFS7ER PUBGC IMPROV DIST
- WES7WAY WCID
• WE57R'OOD SHORFS MUD
- WHARTON CO FD X 01
- WHARTON CO 1R COLL DIST
• WHARTON CO WID M 1(LOUISE WTR)
- WHARTON CO WID X 2(EAST BERNARD W'n
- WHITETAIL RIDCE FD A 03
- WII.LACY CO DRAM DIST X 01
- WILLACY CO DRAIN D[ST Y 02
• WILLACY W EMS
- WILLACY CO HD
- WILLACY CO NAV DIST
• WILSON CO HD
- WILSON PARK RD
• WISECOWCID
- WISECOWDYI(20F2)
• WISE CO WTR SUPPLY DIST
- WOOD W CEN7RAL HOSP DIST
- YOAKUM HD
- ZAPATA CO WCID
Peb 26. 2001 4/ 4
B
CONTRACT FOR TI-IE COLLECTION OF DELINQUENT TA3ES
THE STATE OF TEXAS
COUNTY OF LAMAR
THIS CONTRACT is made and entered into by and between the CIT'I' OF PARIS, acting herein
by and through its goveming body, hereinafrer styled First Party, and the law firm of LINEBARGER
HEARD GOGGAN BLAIR GRAHAM PENA & SAMPSON, LLP, whose address is 1517 West Front
Street, Suite 202, Tyler, Texas 75702, hereinafter styled Second Party.
First Party agrees to employ and does hereby employ Second Party to enforce by suit or
otherwise the collection of taxes, and penalty and interest accrued on those taxes, owing to First Parry and
all other taxing jurisdictions whose taxes are collected by First Party, as provided herein below. Taxes
shall become subject to the terms of this Contract upon the following dates, whichever first occurs: (1) on
February 1 of the year in which the taxes become delinquent if a previously filed tax suit is then pending
against the property subject to the tax; (2) on the date any lawsuit is filed with respect to recovery of the
tax; (3) on the date of filing any application for tax warrant where recovery of the tax or estimated tax is
sought and where the filing of an application for tax warrant by Second Party is at the request of First
Party's Tax Assessor-Collector; (4) on the date of filing any claim in bankruptcy where recovery of the
tax is sought; or (5) on July 1 of the yeaz in which the taxes become delinquent.
II
Second Party is to call to the attention of the collector or other officials any errors, double
assessments or other discrepancies coming under its observation during the progress of the work, and is
to intervene on behalf of First Party in all suits for taxes hereafter filed by any taxing unit on property
located within its corporate limits.
III
First Party agrees to pay to Second Party as compensation for the services required hereunder
fifteen (15%) percent of the amount of all taxes, penalty and interest subject to the terms of this contract
as set forth in Paragraph I above, collected by the Second Party and paid to the collector of taxes during
the term oF this contract, as and when collected. All compensation above provided for shall become the
property of Second Party at the time payment of the taxes, penalty and interest is made to the collector.
The collector shall pay over said funds monthly by check.
IV
In those cases where collection of taxes are enforced by suit, First Party agrees to fumish to
Second Party the name, identity, and location of necessary paRies, together with legal descriptions of
property on which the taxes are due. Second PaRy shall, however, advance all charges and expenses on
behalf of First Party, which are incursed in procuring such information. Any recovery of such expenses
by First Party under TEX. TAX CODE ANN. § 33.48 shall be paid over to Second Party as and when
collected.
V
This contract is drawn to cover a period of _ year(s) beginning and
ending , and shall thereafter continue on a month-to-month basis. Either party
may terminate this contract at the end of the initial contract term or thereafter by giving the other party
thirty (30) days advance notice of termination in writing. During the term of the contract, First Party
shall have the right to terminate this contract following any finding by First Party that Second Party's
performance of its obligations under this contract has been unsatisfactory in material respects; provided
however, that First Party shall grant Second Party 30 days from the date of written notice of such
violation to attempt to cure such; provided further however, that Second Party shall report to First Parry at
least weekly regazding all remedial action taken by Second Party. At the end of this 30-day period, First
Party shall be entitled to consider the reports of remedial activity undertaken by Second Party, and
thereafrer to determine whether Second Party has remedied the unsatisfactory performance. Should
Second Party be found not to have remedied the unsatisfactory performance to the satisfaction of First
Party, First Party may terminate the contract based on the finding ofjust cause. In the case of such
tertnination, Second Party shall be entitled to receive and retain all compensation due up to the date of
said termination. Second Party shall have six (6) months following termination of the contract to reduce
to judgment all suits filed prior thereto. In consideration of the terms and compensation herein stated,
Second Party hereby accepts said employment and undeRakes the performance of said contract as above
written.
This contract is executed on behalf of First Party by the presiding officer of its goveming body
who is authorized to execute this instrument by order heretofore passed and duly recorded in its minutes.
WIT'NESS the signatures of all parties hereto in duplicate originals this the day of
, 2001, Lamar County, Texas.
CITY OF PARIS
First Party
By
Mike Pfeister, Mayor
LINEBARGER HEARD GOGGAN BLAIIt GRAHAM PEP1A & SAMPSON, LLP
Second Party
Rv
For the Firm